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Gates v. Daimlerchrysler Motors Company

November 7, 2007

CURTIS ANTHONY GATES AND SHARON GATES PLAINTIFFS
v.
DAIMLERCHRYSLER MOTORS COMPANY, L.L.C. D/B/A DAIMLERCHRYSLER MOTORS COMPANY, L.L.C. OF DELAWARE F/K/A DAIMLERCHRYSLER MOTORS CORPORATION DEFENDANT



The opinion of the court was delivered by: Wm. R. Wilson, Jr. United States District Judge

ORDER

Pending is Defendant's Motion for Summary Judgment (Doc. No. 42). Plaintiffs have responded (Doc. No. 51).

I. SUMMARY JUDGMENT STANDARD

Summary judgment is appropriate only when there is no genuine issue of material fact, so that the dispute may be decided on purely legal grounds.*fn1 The Supreme Court has established guidelines to assist trial courts in determining whether this standard has been met:

The inquiry performed is the threshold inquiry of determining whether there is the need for a trial -- whether, in other words, there are any genuine factual issues that properly can be resolved only by a finder of fact because they may reasonably be resolved in favor of either party.*fn2

The Court of Appeals for the Eighth Circuit has cautioned that summary judgment is an extreme remedy that should only be granted when the movant has established a right to the judgment beyond controversy.*fn3 Nevertheless, summary judgment promotes judicial economy by preventing trial when no genuine issue of fact remains.*fn4 I must view the facts in the light most favorable to the party opposing the motion.*fn5 The Eighth Circuit has also set out the burden of the parties in connection with a summary judgment motion:

[T]he burden on the party moving for summary judgment is only to demonstrate, i.e.,"[to point] out to the District Court," that the record does not disclose a genuine dispute on a material fact. It is enough for the movant to bring up the fact that the record does not contain such an issue and to identify that part of the record which bears out his assertion. Once this is done, his burden is discharged, and, if the record in fact bears out the claim that no genuine dispute exists on any material fact, it is then the respondent's burden to set forth affirmative evidence, specific facts, showing that there is a genuine dispute on that issue. If the respondent fails to carry that burden, summary judgment should be granted.*fn6

Only disputes over facts that may affect the outcome of the suit under governing law will properly preclude the entry of summary judgment.*fn7

II. BACKGROUND

Plaintiff Curtis Anthony Gates ("Plaintiff") was driving his 2001 Dodge Ram truck on November 16, 2001, on Highway 67 in Jackson County, Arkansas.*fn8 The truck was equipped with an "SRS/Airbag" system, and Plaintiff was wearing his seat-belt.*fn9 Plaintiff was traveling the speed limit, nearing an intersection at which he had the green light, when Defendant failed to yield and turned left into Plaintiff's path.*fn10 The vehicles collided.*fn11 The air-bag system in Plaintiff's truck did not deploy and Plaintiff was injured.*fn12 Plaintiff relies upon strict liability and negligence, and seeks punitive damages.*fn13

III. DISCUSSION

A. Evidence of a Defect

To succeed in a strict liability claim, a plaintiff must prove that a product was defective so as to render it unreasonably dangerous, and that the defect was the cause of the injury.*fn14 When there is no direct proof of a specific defect, a plaintiff may negate other possible causes of the product's failure, not attributable to the defendant, and in this way create the inference that the defect is the defendant's responsibility.*fn15 A plaintiff is not required to prove a specific defect if common experience tells us that, absent a defect, the accident would not have occurred.*fn16

However, the "mere fact of an accident, standing alone" does not prove a plaintiff's case that a ...


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